The First District of the Illinois Appellate Court upheld a $9.8 million award for ICD Publications, Inc. against Ian Gittlitz this December, http://www.state.il.us/court/Opinions/AppellateCourt/2014/1stDistrict/1133277.pdf Mr. Gittlitz had admitted to fraudulently taking more than $1 million in advances on entity distributions, without information to the other two co-owners of ICD Publications, Inc. He had signed an agreement to settle some false expense claims and change accounting controls after being confronted with multiple examples of self-serving claims, but his failure to disclose the additional $1 million in advances was fraudulent, was admitted by him, and invalidated that settlement. The trial court had authority to deny him all compensation as company President and all other moneys otherwise due him as punitive damages for the fraud